FEDERAL GRANTS MANAGEMENT FOR HEALTH CENTERS MISSION: ACHIEVEMENT Operational Excellence Alabama Primary Health Care Association October 5, 2017 Presenter: Adrienne Hurtt
Introduction Adrienne Hurtt, CEO NEVAEH Healthcare Revenue Management Nevaeh Healthcare Revenue Management 2
Objectives Understand the purpose of grants management Understand Financial Integrity Under how and when to refer to the new HRSA Compliance Manual Understand Federal reporting requirements FFR PMS Single Audit Live review of PMS and FFR Nevaeh Healthcare Revenue Management 3
DIVISION OF FINANCIAL INTEGRITY
HRSA DFI Purpose HRSA s Division of Financial Integrity (DFI) uses the 17 management control areas, detailed below, to: Complete Financial Capability Reviews (FCR) of new and prospective grant recipients (recipients) that expend less than $750,000 a year in federal awards and are exempt from federal audit requirements, and targeted recipients that have single audits but were determined by HRSA to be at risk of having inadequate financial management systems or financial instability; Provide recipients with a guide to ensure their existing accounting and personnel policies and procedures (P&P) include the necessary controls that conform to the prescribed standards in 45 CFR 75; Ensure recipient compliance with single audit requirements and audit recommendations relating to inadequate P&P; and Ensure recipients that receive periodic monitoring or site visits have adequate P&Ps. Nevaeh Healthcare Revenue Management 5
17 Control Areas for HRSA 1. Cash Management The recipients must maintain written P&Ps to minimize the time elapsing between the transfer of funds from the Payment Management System (PMS) and the disbursement of those funds by the recipient. The written P&Ps must reference the process for drawdowns from PMS under HHS awards, and: a. Be limited to the minimum amounts needed to cover allowable project costs; b. Be timed in accordance with the actual immediate cash requirements of carrying out the approved project; and c. Not be made to cover future expenditures. Nevaeh Healthcare Revenue Management 6
Control Areas (cont.) 2. Annual Audits The P&Ps must require: a. The preparation of the Schedule of Expenditures of Federal Awards (SEFA) and subsequently determining if an audit is required to be performed in accordance with the Single Audit Act for fiscal years (FY) with expenditures under federal awards of $750,000 or more; b. Selecting and engaging an audit firm to conduct the annual audit; and c. Reports on these audits be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt or nine months after the FY s end. Nevaeh Healthcare Revenue Management 7
Control Areas (cont.) 3. Accounting System The P&Ps must include a detailed description of the accounting system(s), including: a. The ability to report revenue and expenditures separately by federal program; b. Identification in its chart of accounts of all federal awards received and expended and under which federal program; and c. The process of maintaining records pertaining to the source and application of receipts and disbursements, federal awards, authorizations, obligations, unobligated balances, assets, expenditures, and income and interest which must be supported by source documentation. Nevaeh Healthcare Revenue Management 8
Control Areas (cont.) 4. Bank Statements - The P&Ps must: a. Prohibit the individual reconciling the bank statements from opening them; b. Require bank statements be opened and reviewed by a recipient official that is not authorized to sign checks (i.e. treasurer, president, etc.), but who is familiar with its financial activities; c. Require bank statements be reconciled in a timely manner by someone not authorized to sign checks; d. Require the reconciliation be approved by a recipient official outside the payment process but familiar with the financial activities; and e. Define timely (i.e. within 14 days, etc.) if adequate segregation of duties is not possible due to limited staffing, the recipient must document the key bank reconciliation controls that are in place and personnel responsible in the process. Nevaeh Healthcare Revenue Management 9
Control Areas (cont.) 5. Disbursements/Procurement The P&Ps must require: a. Documentation be maintained to support all disbursements and describe how; b. Disbursements be pre-approved and indicate by whom for both small and large dollar purchases; c. Expenditures be reasonable and explain how this should be accomplished (bids, quotes, etc.); d. Blank checks be safeguarded and define how; e. Segregation of duties over creation of vendor accounts/making payments via Electronic Fund Transfer methods and define how; and f. The dollar threshold for determining signatures on checks and designated organization officials authorized to sign checks. Nevaeh Healthcare Revenue Management 10
Control Areas (cont.) 6. Matching or Cost Sharing The P&Ps must include the requirement that matching or cost sharing contributions (including cash and third party in-kind) be: a. Verifiable from the recipient's records; b. Not included as contributions for any other federallyassisted project or program; c. Necessary and reasonable for proper and efficient accomplishment of the project or program objectives; d. Not paid by the federal government under another award (except where authorized by federal statute to be used for cost sharing or matching); and e. Allowable and provided for in the approved budget. Nevaeh Healthcare Revenue Management 11
Control Areas (cont.) 7. Consultants and Contractors The P&Ps must: a. Describe the nature and scope of services that may be outsourced; b. Require in-house capabilities be evaluated before obtaining external assistance; c. Describe the selection process; d. Describe the method for ensuring all procurement transactions are conducted in a manner, which provides full and open competition to the maximum extent practical; To ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft grant applications, or contract specifications, requirements, statements of work, invitations for bids and/or requests for proposals, will be excluded from competing for such procurements. e. Describe the method for ensuring costs and fees are reasonable; and f. Require that, prior to selecting a new consultant or contractor, the Excluded Parties List System, within the System for Award Management (SAM) at https://www.sam.gov/portal/public/sam/, be checked to ensure the individual or recipient is not prohibited from receiving federal funds. Nevaeh Healthcare Revenue Management 12
Control Areas (cont.) 8. Expenditure Analysis The P&Ps must describe: a. The ability to compare expenditures with budget amounts for each award to ensure total costs do not exceed the amounts budgeted for the grant period; and b. The manner in which significant variances between actual and budgeted expenditures are resolved and documented. Nevaeh Healthcare Revenue Management 13
Control Areas (cont.) 9. Indirect Costs If applicable, the P&Ps must describe: a. Existing or planned indirect cost rates and the type of rate used as well as both the content of pooled expenses and the type of allocation base used; b. If all costs are direct, the method used to allocate costs benefiting multiple cost objectives to each cost objective; c. How and when the rate proposal is prepared, submitted and personnel responsible; and d. The approval process of indirect cost rate reimbursement, matching or cost sharing. Nevaeh Healthcare Revenue Management 14
Control Areas (cont.) 10. Credit Cards The P&Ps must: a. Describe how credit card use is controlled; b. List personnel and purchasing agents authorized to have and use credit cards; c. Require all expenditures be pre-approved; d. Limit individual amounts and types of expenditures that may be incurred; e. Prohibit personal expenditures; and f. Require receipt submission for review and comparison with credit card statements. Nevaeh Healthcare Revenue Management 15
Control Areas (cont.) 11. Timekeeping The P&Ps must: a. Describe timekeeping controls and plans to monitor compliance with federal statutes, regulations, and the terms and condition of the federal award; b. Describe the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, that include the total activity for which employees were compensated; and c. State that Timesheets must be certified as accurate by either the employee or a supervisor familiar with the employee's activities. d. Non-profit organizations cannot charge salary and wages to federal awards based on budget estimates. However, States, Local or Indian Tribal Governments may allocate salary and wages charges to federal awards based on budget estimates, other distribution percentages, or use a substitute system if certain conditions are met in 45CFR 75.430. Nevaeh Healthcare Revenue Management 16
Control Areas (cont.) 12. Travel The P&Ps must: a. Describe programmatic requirements for travel (i.e. budget for travel, restrictions for travel on specific programs); b. Require travel other than local mileage be pre-approved by a recipient approving official; c. Require all travel be reasonable and describe how this is determined; d. Limit mileage, meals and incidentals, and lodging charged to federal programs to the rates published in the Federal Travel Regulations, unless otherwise justified; e. Limit airfare to coach and car rental to mid-sized, unless otherwise justified; and f. Reimburse travel costs based on expenditures reports or the like listing each cost individually along with original receipts. Nevaeh Healthcare Revenue Management 17
Control Areas (cont.) 13. Property Control The P&Ps must require: a. Property records be maintained that include a description, cost, purchase date, source of funding, location, and condition of each property item; b. Periodic physical inventories be taken and reconciled to the property records no less frequently than every other year; c. Property purchased with Government funds be tagged; d. Property be safeguarded to prevent loss or theft and describe how; and e. Disposition requirements for property obtained with federal funds Nevaeh Healthcare Revenue Management 18
Control Areas (cont.) 14. Conflict of Interest Recipients must establish P&Ps to prevent employees, consultants, members of governing bodies, and others involved in grant-supported activities from using their positions for purposes that are, or give the appearance of being, motivated by a desire for private financial gain for themselves or others, such as those with whom they have family, business, or other ties. The P&Ps must: a. Address the conditions under which outside activities, relationships, or financial interests are proper or improper; b. Provide for advance notification of outside activities, relationships, or financial interests to a responsible organizational official; c. Include a process for notification and review by the responsible official of potential or actual violations of the standards; and d. Specify the nature of penalties that may be imposed for violations. Nevaeh Healthcare Revenue Management 19
Control Areas (cont.) 15. Mandatory disclosures The P&Ps must: 1. Include a process to disclose, in a timely manner, in writing to HHS all violations of federal criminal law, involving fraud, bribery, and gratuity violations potentially affecting the award. 2. If applicable, address all other standard terms in the NOA (i.e., Civil Rights Act of 1964 (Title VI), human trafficking, etc.). Nevaeh Healthcare Revenue Management 20
Control Areas (cont.) 16. Allowability of Costs The P&Ps must address the allowability of costs per the specific program or source such as the Funding Opportunity Announcement: a. To be allowable under a federal award, costs must be reasonable, allocable, and adequately documented; b. A cost is reasonable if it does not exceed what a prudent person would incur under similar circumstances; c. A cost is allocable to a federal award to the extent the goods or services benefited the program; and d. A cost is adequately documented if it is supported by accounting records and source documentation such as purchase orders, vouchers, invoices, payroll allocation reports, payroll summaries, timesheets, etc. Nevaeh Healthcare Revenue Management 21
Control Areas (cont.) 17. Program Income The P&Ps must: a. Limit the use of program income relating to projects financed with federal funds to one or more of the following: I. Furthering the eligible project or program objectives; II. III. Financing the non-federal share of the project or program; or Deducting it from the total federal share of project or program allowable costs. b. Detail how the program income is calculated and under what conditions the program income is to be used. Nevaeh Healthcare Revenue Management 22
HRSA COMPLIANCE MANUAL NEVAEH Healthcare Revenue Management
HRSA Compliance Manual https://bphc.hrsa.gov/programrequirements/summary.html https://bphc.hrsa.gov/programrequirements/pdf/healthcent ercompliancemanual.pdf Nevaeh Healthcare Revenue Management 24
Overview The Health Resources and Services Administration s (HRSA) Bureau of Primary Health Care (BPHC) is responsible for effective and efficient oversight of the Health Center Program. This includes ensuring that health centers comply with applicable statutory and regulatory requirements for the Health Center Program. The Health Center Program Compliance Manual serves as a streamlined and consolidated resource to assist health centers in understanding and demonstrating compliance with Health Center Program and Federal Torts Claims Act program requirements. Nevaeh Healthcare Revenue Management 25
Chapter 15: Financial Management and Accounting Systems Requirements 1. The health center must maintain effective control over, and accountability for, all funds, property, and other assets in order to adequately safeguard all such assets and ensure that they are used solely for authorized purposes. 2. The health center must develop and utilize financial management and control systems in accordance with sound financial management procedures which ensure at a minimum: 3. The fiscal integrity of grant financial transactions and reports; and 4. Ongoing compliance with Federal statutes, regulations, and the terms and conditions of the Health Center Program award or designation. Nevaeh Healthcare Revenue Management 26
Requirements (cont.) 5. The health center s financial management system must specifically identify in its accounts all Federal awards, including the Federal award made under the Health Center Program, received and expended and the Federal programs under which they were received (see 45 CFR 75.302). This financial management system must also provide for all of the following: 6. Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements (see 45 CFR 75.341 and 75.342); 7. Records that identify the source (receipt) and application (expenditure) of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest, and be supported by source documentation (see: 45 CFR 75.302(b)(3)); 8. Written procedures that minimize the time elapsing between the transfer of Federal award funds from HHS and the disbursement of these funds by the health center (see 45 CFR 75.305); 9. Written procedures for assuring that expenditures of Federal award funds are allowable in accordance with the terms and conditions of the Federal award and with the Federal Cost Principles (see 45 CFR Part 75 Subpart E). Nevaeh Healthcare Revenue Management 27
Requirements (cont.) 10. A health center that expends $750,000 or more in Federal awards during its fiscal year must have a single or programspecific audit conducted for that year in accordance with the provisions of 45 CFR Part 75 Subpart F. 11. The health center must use any non-grant funds as permitted under section 330, and may use such funds for such other purposes as are not specifically prohibited under section 330, if such use furthers the objectives of the [health center] project. Nevaeh Healthcare Revenue Management 28
Demonstrating Compliance A health center would demonstrate compliance with these requirements by fulfilling all of the following: a. The health center has and utilizes a financial management and internal control system that reflects Generally Accepted Accounting Principles (GAAP) for private non-profit health centers or Government Accounting Standards Board (GASB) principles for public agency health centers and that ensures at a minimum: 1. Health center expenditures are consistent with the HRSA-approved total budget and with any additional applicable HRSA approvals that have been requested and received; 2. Effective control over, and accountability for, all funds, property, and other assets associated with the Health Center Program project; 3. The safeguarding of all assets to assure they are used solely for authorized purposes in accordance with the terms and conditions of the Health Center Program award/designation; and 4. The capacity to track the financial performance of the health center, including identification of trends or conditions that may warrant action by the organization to maintain financial stability. Nevaeh Healthcare Revenue Management 29
Demonstrating Compliance (cont.) The health center s financial management system is able to account for all Federal award(s) (including the Federal award made under the Health Center Program) in order to identify the source (receipt) and application (expenditure) of funds for federally funded activities in whole or in part. Specifically, the health center s financial records contain information and related source documentation pertaining to authorizations, obligations, unobligated balances, assets, expenditures, income, and interest under the Federal award(s). The health center has written procedures for: a. Drawing down Federal award funds in a manner that minimizes the time elapsing between the transfer of the Federal award funds from HRSA and the disbursement of these funds by the health center; and b. Assuring that expenditures of Federal award funds are allowable in accordance with the terms and conditions of the Federal award and with the Federal Cost Principles in 45 CFR Part 75 Subpart E. Nevaeh Healthcare Revenue Management 30
Demonstrating Compliance (cont.) The health center determines which accounting software and related systems to use for financial management. The health center determines the type, frequency, and format of financial reports used to support the board and the key management staff s ability to carry out its oversight responsibilities. The health center determines which specific actions to take in response to negative financial trending and its method for monitoring the results of those actions. Nevaeh Healthcare Revenue Management 31
Chapter 17: Budget Requirements The health center must develop an annual budget that: 1. Identifies the projected costs of the Health Center Program project; 2. Identifies the projected costs to be supported by Health Center Program [award] funds, consistent with Federal Cost Principles1 and any other requirements or restrictions on the use of Federal funding; and 3. Includes all other non-federal revenue sources that will support the Health Center Program project, including: a. State, local, and other operational funding; and b. Fees, premiums, and third-party reimbursements which the health center may reasonably be expected to receive for its operation of the Health Center Program project. The health center must submit this budget annually by a date specified by HRSA for approval through the Federal award or designation process. Nevaeh Healthcare Revenue Management 32
Chapter 16: Billing & Collections Requirements The health center must prepare a schedule of fees for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation. The health center must assure that any fees or payments required by the center for health care services will be reduced or waived in order to assure that no patient will be denied such services due to an individual s inability to pay for such services. The health center must establish systems for eligibility determination and for billing and collections [with respect to third party payors]. The health center must make every reasonable effort to enter into contractual or other arrangements to collect reimbursement of its costs with the appropriate agency(s) of the State which administers or supervises the administration of: 1. A State Medicaid plan approved under title XIX of the Social Security Act (SSA) [42 U.S.C. 1396, et seq.] for the payment of all or a part of the center's costs in providing health services to persons who are eligible for such assistance; and 2. The Children s Health Insurance Program (CHIP) under title XXI of the SSA [42 U.S.C. 1397aa, et seq.] with respect to individuals who are State CHIP beneficiaries. Nevaeh Healthcare Revenue Management 33
Billing & Collections (cont.) The health center must make and continue to make every reasonable effort to collect appropriate reimbursement for its costs on the basis of the full amount of fees and payments for health center services without application of any discount when providing health services to persons who are entitled to: 1. Medicare coverage under title XVIII of the SSA [42 U.S.C. 1395 et seq.]; 2. Medicaid coverage under a State plan approved under title XIX of the SSA [42U.S.C. 1396 et seq.]; or 3. Assistance for medical expenses under any other public assistance program (for example, CHIP), grant program, or private health insurance or benefit program. The health center must make and continue to make every reasonable effort to secure payment for services from patients, in accordance with health center fee schedules and the corresponding schedule of discounts. Nevaeh Healthcare Revenue Management 34
Chapter 9: Sliding Fee Discount Requirements The health center must operate in a manner such that no patient shall be denied service due to an individual s inability to pay. The health center must prepare a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and must prepare a corresponding schedule of discounts [sliding fee discount schedule (SFDS)] to be applied to the payment of such fees or payments, by which discounts are adjusted on the basis of the patient's ability to pay. The health center must establish systems for [sliding fee] eligibility determination. The health center s schedule of discounts must provide for: o A full discount to individuals and families with annual incomes at or below those set forth in the most recent Federal Poverty Guidelines (FPG) [100 percent of the FPG], except that nominal charges for service may be collected from such individuals and families where imposition of such fees is consistent with project goals; and o No discount to individuals and families with annual incomes greater than twice those set forth in such Guidelines [200 percent of the FPG]. Nevaeh Healthcare Revenue Management 35
FINANCIAL COMPLIANCE NEVAEH Healthcare Revenue Management
Financial Reporting for BOD and Management Standard Monthly Contract oversight report (sub-recipients and contracting agencies), critical indicator expectations/projections to actual experience, monthly and year to date Annual operating plan goals and objectives, projections to actual experience, current month and year to date Balance sheet and revenue and expenditure report, summary level and breakout by clinic site, department and/or program current month and year to date Budget variance reports, budget to actual, by clinic site, department and/or program current month and year to date Number of days cash on hand Federal drawdown, current month and year to date Encounters, budget to actual, by clinic site, department and/or program; and, new patient encounters current month, year to date, comparison to prior year Aged accounts receivable Aged accounts payable Nevaeh Healthcare Revenue Management 37
Financial Reporting for BOD and Management (cont.) Standard Quarterly Long range goals and objectives, projections to actual experience, current quarter and year to date Payor mix aggregate and by clinic location/department, budget to actual Percent of revenues from patient services versus grants, budget to actual Denial rate by payor source aggregate, by clinic site, department and/or program, by provider Appointment experience total volume, missed/canceled and walk-in experience by time of day and day of week Productivity by provider encounters by provider per hour, per month and year-to-date and number of RVUs associated with monthly encounters compared to budget Nevaeh Healthcare Revenue Management 38
Financial Reporting for BOD and Management (cont.) Financial Ratios and Other Performance Indicators 1. Current Ratio 2. Debt Management Ratio 3. Working Capital 4. Ratio of provider to other staff, current month and year to date 5. BPHC Performance Indicators/UDS site specific and state rollup 6. Coding levels for new and established patient office visits, by provider and aggregate for the center, compared to national norms Charges by provider Net revenue by provider Claims denials by provider Ratio of collections to salary dollars by provider Cost and average revenue per encounter, aggregate and by clinic location/department Cost per RVU, current month and year to date Nevaeh Healthcare Revenue Management 39
SINGLE AUDITS NEVAEH Healthcare Revenue Management
Single Audit Background on the federal law governing nonprofit audits The government passed the Single Audit Act of 1984 to ensure that those organizations receiving substantial federal funds use the funds in compliance with the federal government s funding requirements. The Act refers to a single audit because one of the objectives of the law is to replace the need for the federal government to audit the same non-governmental organization multiple times. The stated purpose of the law is to promote sound financial management of government funds by non-federal organizations, promote uniform guidelines for audits, and reduce burdens on government and nonprofits by promoting efficient and effective use of audit resources. The OMB explains it this way: "A single audit is intended to provide a cost-effective audit for non-federal entities in that one audit is conducted in lieu of multiple audits of individual programs." (Source: White House Office of Management and Budget) Nevaeh Healthcare Revenue Management 41
Single Audit (cont.) Subpart F, Audit Requirements, applies to audits of non- Federal entity fiscal years beginning on or after December 26, 2014 (the first fiscal year that begins after December 26, 2014). For a calendar year end entity, these requirement become effective for December 31, 2015 year end audits. A full comparison of audit requirements under OMB Circular A- 133 and Uniform Guidance Subpart F can be found here: Audit Requirements Comparison Chart (Source: COFAR). - See more at: https://www.councilofnonprofits.org/nonprofit-auditguide/federal-law-audit-requirements#sthash.2d2kizti.dpuf Nevaeh Healthcare Revenue Management 42
Single Audit (cont.) The requirement for a nonprofit to conduct a Single Audit is triggered when a nonprofit receives federal funds from either one or several government funding sources (whether in the form of a government contract or a grant) AND when that nonprofit expends $750,000 or more in federal funding in a single year. Federal funding means either money that originated directly from the federal government, or funds that came to the nonprofit from a pass-through entity, such as a state or local government agency. This is called a subrecipient relationship. In determining the total amount of federal funds expended, funds directly from federal agencies, as well as those federal funds received from pass-through entities, such as state government or other non-federal recipients, are included. Nevaeh Healthcare Revenue Management 43
Single Audit (cont.) How is a single audit different from a regular independent audit? What is its scope? A single audit covers the entire scope of the organization s financial operations, ensuring that: The financial statements are presented fairly; The organization has an adequate internal control structure, and that; The organization is in compliance with any special government regulations/laws that apply to the specific type of federal funding the audit covers. Nevaeh Healthcare Revenue Management 44
Single Audit (cont.) A Single Audit is significantly more detailed than a regular independent audit. Compliance with the Single Audit Act requires nonprofit organizations and their auditors to conduct an audit in accordance with the new Uniform Guidance. Auditors performing Single Audits are required to receive a heightened level of certification in order to perform such audits. There are specific and higher levels of testing that must be done on expenses to ensure that the federal funds have been used properly, as well as documented and reported correctly in the nonprofit's financial statements. Additionally, auditors are required to verify compliance with regulations specific to the program or grant for which funds were expended. Nevaeh Healthcare Revenue Management 45
Single Audit (cont.) In order to be certain all federal funds are accounted for in determining whether you meet the threshold for a single audit, your auditor should obtain documentation from pass-through entities sufficient to determine whether any of the funds you received as payment for services were federal, and if so how much. The single audit must be completed and submitted in machine-readable format to the Federal Audit Clearinghouse either 30 days after receiving the auditor s report, or nine months after the end of the nonprofit s fiscal year, whichever comes earlier. The single audit also must be submitted to any pass-through entity, if applicable, and Copies of the audit report must be made available to the public. Nevaeh Healthcare Revenue Management 46
Single Audit (cont.) CFR Section 200.514(b) requires that a Single Audit must include a determination of whether the financial statements of the auditee are presented in accordance with generally accepted accounting principles. The costs of auditing the financial statements are allowable in-direct costs for nonfederal entities subject to the requirements of the Single Audit Act. Nevaeh Healthcare Revenue Management 47
Finance Internal Controls CEO/CFO team oversight Finance Committee Multiple Signatures/Authorizers Authority Thresholds/Levels Policies and Procedures Audit Fraud and Employee Theft Protection Internal audits on regular basis Other suggestions Nevaeh Healthcare Revenue Management 48
Other Compliance Areas Medicare (MC) Credit Balance Report Progress Reports Grant Quarterly Reporting Foundation Reporting Annual Reports Nevaeh Healthcare Revenue Management 49
Reports to Know FFR Federal Financial Report Due Annually, 90 days after year end PMS Payment Management System Due Quarterly for Drawdowns, at the end of the quarter Nevaeh Healthcare Revenue Management 50
Sample FFR Tutorial https://help.hrsa.gov/display/public/ehbskbfg/ffr+- +Transactions#FFR-Transactions-TransactionSectionVideo Nevaeh Healthcare Revenue Management 51
OPEN DISCUSSION NEVAEH Healthcare Revenue Management
Contact Information Adrienne Hurtt Email: adriennehurtt@msn.com Nevaeh Healthcare Revenue Management 53